IRS Proposed Regulations Under Internal Revenue Code Section 965

United States

09/04/2018

Morgan Lewis

On August 1, 2018, the Internal Revenue Service took the first step in providing significant and detailed guidance on provisions of the Tax Cuts and Jobs Actwith the issuance of proposed regulations (the Proposed Regulations) under Section 965 of the Internal Revenue Code of 1986, as amended, or the so-called “Repatriation Tax.” Prior to the issuance of the Proposed Regulations, the IRS had published preliminary guidance on Section 965 through the issuance of several notices and other informal directives. The Proposed Regulations follow and reflect the preliminary guidance in most respects, but also introduce a handful of new and noteworthy provisions.